Spring 2026 Archives

Editor's Message

Moving Beyond the Abstract

This issue of the EA Journal lives where many practitioners increasingly find themselves: at the intersection of corporate decision-making and cross-border reality. Even when clients insist they are "just a small business," entity choice, owne... Jeremy Wells, EA, CPA

Spring 2026, Editor's Message, S Corporations, C Corporations, international, practice management

Tax Planning

Why Language, Not Math, Is the First Thing That Goes Wrong with Entity Structure Problems

Consider the following scenario: Two founders form a limited liability company (LLC) taxed as a partnership. For years, they have referred to their interests as “stock.” When one founder exits, they describe the transaction as a “stock sale.” The buyer as... Juan Ojeda Jr.

Spring 2026, Tax Planning, partnership, LLC, limited liability company, stock, §754

Member Profile

José Fuentes Jiménez

Where do you reside? I live in Paris, France. What got you involved in the tax profession? As an immigrant in France, I often received questions from fellow immigrants and expatriates (expats) on how to better organize... José Fuentes Jiménez, EA

Spring 2026, Member Profile, practice management

Capitol Corner

Outlook for 2026 — Congress, the Internal Revenue Service, and What It Means for Enrolled Agents

As we look ahead to 2026 and the policy that could impact enrolled agents and taxpayers, we anticipate this year to be one of continued partisan division and the beginning of a transition with the midterm elections at the end of th... Michelle McCaughey, Thad Inge, Samantha Ford

Spring 2026, Capitol Corner, advocacy, Taxpayer Protection and Preparer Proficiency Act, OBBBA

Feature Article

Evolution of the Tax Home Concept as a Legal Term of Art*

Tax home is, particularly when considered in an international context, a curious legal term with a specific meaning that is at odds with what it superficially suggests. Counterintuitively enough, it does not patently mean the... Anthony (“Tony”) Malik, EA

Spring 2026, Feature Article, tax home, Revenue Act of 1921, §214(a)(1), Bixler v. Commissioner, Lindsay v. Commissioner, Stairwalt v. Commissioner, Chandler v. Commissioner, Conner v. Commissioner

Feature Article

Foreign Corporations, Form 5471, and the Perils of Offshore Noncompliance

Form 5471 is required to be filed by United States (U.S.) persons—citizens, resident aliens, domestic partnerships, and corporations, and certain estates and trusts—who are officers, directors, or 10... Manasa Nadig, EA

Spring 2026, Feature Article, FBAR, Schedule C, GILTI, Schedule E, Form 8938, Form 926, Form 5471, Form 3520, Form 3520-A, fair market value, Schedule A, CDP, §965, controlled foreign corporation, CFC, Schedule I, FMV, Schedule F, Schedule B, Farhy v. Commissioner, §6038(c), foreign corporation, offshore noncompliance, §6679, §6046, §6038B(c), §318, Treas. Reg. §1.6046-1(i), §958(a), §958(b), Schedule G, §6013, Schedule H, Schedule M, Schedule O, Schedule P, Schedule Q, Schedule R, §6677, Raj J. Mukhi

Feature Article

The Debate Between S Elections and C Elections: The Overlooked Case of Profit Projections

Few decisions in entity structuring spark more debate among tax practitioners than whether a closely held business should elect S corporation or C corporation treatment. Online forums, continuing educati... Elan Becker, EA

Spring 2026, Feature Article, TCJA, Tax Cuts and Jobs Act, s corporation, c corporation, §199A, AMT, Alternative minimum tax, Form 2553, Form 8832, specified service trade or business, SSTB, S election, C election, entity choice, qualified business income deduction, QBID, §1202, qualified small business stock, QSBS, §1361, §1379, §1362, Fact Sheet FS-2008-25, net investment income tax, NIIT, accumulated earnings tax, AET, §531, §1372, David E. Watson, P.C. v. United States

EVP Message

Growing the Profession

Over the last few years, it seemed that the enrolled agent (EA) credential was moving from a quiet constant in the tax profession to a rapidly growing force shaping its future. As tax law grows more complex and demand for specialized, year-round expertise increases, more professiona... Megan Killian

Spring 2026, EVP Message, practice management

President's Message

Building Community

I find it hard to believe my year as president is already beginning to wind down. The honor of serving the National Association of Enrolled Agents (NAEA) community has been a far greater pleasure than I imagined it would be when I started down this path. I suppose I shoul... Jennifer MacMillan, EA

Spring 2026, President's Message, advocacy, practice management

Feature Article

Caught Between Two Tax Systems: Practical Guidance on the U.S.–Italy Tax Treaty and Totalization Agreement

Practical Guidance on the U.S.–Italy Tax Treaty and Totalization Agreement Cross-border tax issues between the United States (U.S.) and Italy are increasingly common, especially amo... Luca Pizzale, EA, CPA

Spring 2026, Feature Article

Practice Builder

Where Did the Money Go? The Question Most Firm Owners Ask Quietly

January 21, 2026, had been circled on Dan’s calendar for years. He had been setting money aside quietly. Not for the firm, but for something personal. After a long stretch of growth, he wanted to mark his 25th wedding anniversar... Harris Kamal, EA

Spring 2026, Practice Builder, practice management